Series on International Taxation

Permanent establishment is the key concept for allocating taxation rights in respect of business income, and the question 舖Is there a permanent establishment?舗 is a tax treaty issue that advisers, government officials, and courts perennially confront. Based on a 舖fixed link to the ground舗, the idea has become progressively more difficult to apply until, at this stage, re-evaluation has become a political necessity. If a permanent establishment may exist in the context of e-commerce, the concept of a geographical presence must be redefined. However, the question remains: is e-commerce a sufficient reason for challenging the well-established permanent establishment nexus?